20180720Staff 11-12 to REC.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC., J.R.
SIMPLOT COMPANY, AND RENEWABLE
ENERGY COALITION FOR MODIFICATION
OF THE 90/110 PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
CASE NO.IPC-E-18-07
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
RENEWABLE ENERGY
COALITION
REC E IVED
I*!$.lUL 20 PH Z: I I
SSION
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, request that Renewable Energy Coalition (REC) provide
the following documents and information as soon as possible, by FRIDAY, AUGUST 10,2018.
This Production Request is continuing, and REC is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. REC is reminded that responses pursuant to
Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
THIRD PRODUCTION REQUEST TO
RENEWABLE ENERGY COALITION 1 JULY 20,2018
REQUEST NO. 11: In "Idahohydro, Shorock Hydro, Inc., J.R. Simplot Company and
Renewable Energy Coalition's Petition," the Petitioners state in Paragraph 20 that "...actual
O&M costs for QF interconnected interests instructs that annual, percentage-based charges in
most, if not all, cases far exceed the actual O&M expenses for QF interconnection facilities, thus
indicating that the average O&M on IPCo system-wide transmission and distribution facilities is
either inapplicable or inaccurate as a reflection of the cost of O&M actually performed on QF
interconnection facilities." Please answer the following questions :
a. Please provide evidence that supports "the average O&M on IPCo system-wide
transmission and distribution facilities is either inapplicable or inaccurate as a
reflection of the cost of O&M actually performed on QF interconnection facilities".
b. Please define "actual O&M costs for QF interconnected interests."
c. Please provide a list and a detailed description of the types of O&M costs that
Renewable Energy Coalition believes a QF should be responsible for paying.
REQUEST NO. 12: If Idaho Power offers the option of charging actual O&M costs for
interconnections used by QF projects, please explain how QFs would financially cope with
catastrophic events that may cause significant damage to interconnection facilities?
Dated at Boise, Idaho, this
i :umisc:prodreq/ipce I 8. Tepyy prod req3 Renewable Energy Coal ition
THIRD PRODUCTION REQUEST TO
RENEWABLE ENERGY COALITION
of July 2018
Pacillo
Deputy Attorney General
2M,
2 JULY 2O,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF JULY 2018,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO RENEWABLE ENERGY COALITION IN CASE NO
IPC-E-I8-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
DONOVAN WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : dwalker@,idahopower. com
dockets@ idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-mail: [e-mail]
J KAHLE BECKER
ATTORNEY AT LAW
223 N 6TH STREET #325
BOISE ID 83702
E-mail : [e-mail]
TAMARACK ENERGY PARTNERSHIP
c/o MICHAEL C CREAMER
PRESTON N CARTER
60I W BANNOCK
BOISE ID 83702
E-mail: [e-mail]
pnc@si com
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
1411 E MISSION AVE, MSC-7
SPOKANE WA992O2
E-mail: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail : [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
gre e@richardsonadams. com
IRION SANGER
SANGER LAW PC
I I I7 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
14I I E MISSION AVE, MSC-23
SPOKANE WA992O2E-mail:u1lahacl@
-t4^w
CERTIFICATE OF SERVICE